🔬 Chemicals × REACH — Corporate Response Case Studies
Track how global companies are responding to major environmental regulations, categorized by framework. Identify stances, strategies, and key implementation hurdles.
📋 About the Listed Information (Disclaimer)
The information on this page is compiled from official disclosures. Stances evolve as regulatory definitions shift. Verify with primary sources before making business decisions.
Fulfilling article manufacturer duties. Managing SVHC reporting via chemSHERPA.
SVHC 0.1wt% threshold compliance, supply chain-wide chemical surveys
BASF
BASF SE
GermanyChemicals
Adapting
⚡ Managing an expanding SVHC list and REACH restrictions while cutting costs; according to BASF, it reached an annual cost-savings run rate of about €1.7 billion at the end of 2025
BASF, the German chemical company, faces continuing REACH obligations as an EU-based manufacturer: the expanding SVHC Candidate List, authorisation (Annex XIV) and restrictions (Annex XVII). The SVHC Candidate List reached 253 entries with the February 4, 2026 update, which added n-hexane and Bisphenol AF (BPAF). On April 27, 2026, the European Commission said it would not open REACH for a full revision at this stage (the European Parliament Legislative Train lists the file as "Blocked", as updated on September 20, 2026). According to the company (February 27, 2026), BASF reached an annual cost-reduction run rate of around €1.7 billion by the end of 2025 and expects annual cost savings of €2.3 billion by the end of 2026, including a programme focused on its Ludwigshafen site. Balancing REACH compliance costs with profitability is a core management task.
🎯 Key Initiatives
Cost savings: according to the company, an annual cost-reduction run rate of around €1.7 billion was reached by the end of 2025, and annual savings of €2.3 billion are expected by the end of 2026 (press release, February 27, 2026).
Ludwigshafen: the cost-savings programmes include one focused on the Ludwigshafen site (company press release).
SVHC additions: for the substances added in February 2026 (n-hexane, BPAF), SDSs and customer information need updating, and producers and importers of articles containing them above 0.1% w/w became subject to ECHA notification (REACH Article 7(2)) from August 4, 2026.
PFAS: the universal PFAS restriction proposal under REACH Annex XVII is relevant to coatings additives and other product lines (GRI's analysis).
⚠️ Challenges & Risks
•Pace of SVHC additions: each update requires SDS revisions, SCIP information, customer communication and, where needed, development of alternatives across a large product portfolio. The SVHC Candidate List is usually updated twice a year; in 2026 it was updated once (February 4), and the next update is expected in June 2027.
•After the REACH revision was shelved: concerns about re-registration costs from a major overhaul of registration and authorisation have receded, but new Candidate List entries and new Annex XVII restrictions still need to be handled.
•Performance and qualification gaps: alternatives to SVHCs or PFAS may not match existing products in some uses, and customer requalification in semiconductors, automotive and aerospace can take years.
📢 Ongoing Compliance🕐 Verified: October 2026 Verified🔍 Last source review: 2026-10-18
GRI Editorial Comment
BASF's REACH card shows a large chemical producer handling continuing REACH obligations while restructuring for cost. According to the company, its cost-reduction run rate reached about €1.7 billion at the end of 2025. GRI's suggestion for Japanese chemical and materials companies: with 253 Candidate List entries (February 2026), every company supplying the EU market needs to know the SVHC content of its products and keep its SCIP information up to date. The shelving of the REACH revision in April 2026 reduces the risk of an immediate overhaul, but routine obligations continue.
The SVHC Candidate List is usually updated twice a year; in 2026 it was updated once (February 4), and the next update is expected in June 2027. Please check the ECHA website and BASF's official website for the latest information.
Dow
The Dow Chemical Company
USAChemicals & Materials
Adapting
⚡ Scaling back European capacity while continuing REACH compliance as a non-EU manufacturer
Dow, a US-based materials science company headquartered in Midland, Michigan, complies with EU REACH as a non-EU manufacturer; REACH Article 8 allows such manufacturers to register through an Only Representative (OR) in the EU. According to the company, on June 30, 2025 its board approved closing three European assets: an ethylene cracker in Böhlen and chlor-alkali and vinyl assets in Schkopau (Germany), both expected to shut down in the fourth quarter of 2027, and a basic siloxanes plant in Barry (UK), expected to shut down in mid-2026. In April 2025 the company expanded its review of European assets, primarily in polyurethanes, and delayed construction of its Path2Zero project in Fort Saskatchewan, Canada, until market conditions improve. On April 27, 2026, the European Commission said it would not open REACH for a full revision at this stage (the European Parliament Legislative Train lists the file as "Blocked", as updated on September 20, 2026).
🎯 Key Initiatives
European closures: according to the company, the board approved closing Böhlen (ethylene) and Schkopau (chlor-alkali and vinyl) in Germany, expected to shut down in Q4 2027, and Barry (basic siloxanes) in the UK, expected to shut down in mid-2026 (June 30, 2025).
Charges: the company recorded $330 million to $360 million of asset write-downs and write-offs in Q2 2025.
European asset review: in April 2025 the company expanded its review of European assets, primarily in polyurethanes.
Path2Zero: in April 2025 the company delayed construction until market conditions improve, reducing its planned 2025 capital expenditure from $3.5 billion to $2.5 billion.
REACH compliance: as a non-EU manufacturer, it needs to maintain registrations, SDSs and SVHC information for products exported to the EU.
⚠️ Challenges & Risks
•Maintaining compliance while shrinking in Europe: registrations, SVHC information and SDSs must continue for product lines still exported to the EU; registrations tied to divested businesses need to be transferred.
•PFAS restriction proposal: after the RAC final opinion (March 3, 2026) and the SEAC final opinion (expected by end-2026), the Commission will propose a restriction for a vote in the REACH Committee; identifying PFAS-containing products and preparing alternatives will matter for EU market access.
•Regulatory gaps: On April 27, 2026, the European Commission said it would not open REACH for a full revision at this stage (the European Parliament Legislative Train lists the file as "Blocked", as updated on September 20, 2026). Differences between US TSCA and EU REACH continue to require parallel compliance.
📢 Ongoing Compliance🕐 Verified: October 2026 Verified🔍 Last source review: 2026-10-18
GRI Editorial Comment
Dow's REACH card shows a company scaling back its European exposure while continuing to comply with REACH. The closures approved in June 2025 and the expanded review of European assets are based on economic factors, but they also reduce the scope of its REACH obligations in Europe. GRI's suggestion for Japanese chemical and materials companies: a company without EU production that exports chemicals to the EU registers through an Only Representative, like a non-EU manufacturer such as Dow, and changes in its European business need to be planned together with its REACH registration structure.
Dow's European asset review, the Path2Zero schedule and the PFAS restriction proposal may change. Please check Dow's investor relations pages and the ECHA website for the latest information.
Evonik Industries
Evonik Industries AG
GermanySpecialty Chemicals
Adapting
⚡ Restructuring a specialty chemicals portfolio while maintaining REACH compliance
Evonik is a specialty chemicals company headquartered in Essen, Germany. According to the company, its 2025 sales fell by 7% to €14.1 billion, adjusted EBITDA was €1.87 billion, and it expects adjusted EBITDA of €1.7–2.0 billion in 2026; it has about 31,000 employees. In June 2026 it extended its efficiency programme "Evonik Tailor Made" through 2029, with about 3,200 jobs to be cut (2,150 in Germany) and its polyester business to be discontinued. On April 27, 2026, the European Commission said it would not open REACH for a full revision at this stage (the European Parliament Legislative Train lists the file as "Blocked", as updated on September 20, 2026).
🎯 Key Initiatives
2025 results: according to the company, sales of €14.1 billion (down 7%) and free cash flow of €695 million; adjusted EBITDA of €1.7–2.0 billion expected for 2026.
Advanced Technologies: 2025 revenue of €5.97 billion (down 2%) and adjusted EBITDA of €944 million (margin 15.8%), according to the company.
Custom Solutions: 2025 revenue of €5.49 billion (down 4%), according to the company.
Tailor Made extension (June 2026): restructuring and savings measures through 2029, about 3,200 jobs to be cut and the polyester business to be discontinued; separately, about 2,800 positions were to be cut from October 2023 to the end of 2026.
⚠️ Challenges & Risks
•Cost per product: Candidate List updates require SDS revisions, SCIP information and customer communication, which weigh more on low-volume products. The SVHC Candidate List is usually updated twice a year; in 2026 it was updated once (February 4), and the next update is expected in June 2027.
•Registration transfers: for businesses that are sold or discontinued, changes of REACH registrants, SDS issuers and parties providing SCIP information need to be managed.
•Restructuring and results: delivering the 2026 adjusted EBITDA outlook of €1.7–2.0 billion while continuing REACH compliance is a financial task.
📢 June 2025 Announcement🕐 Verified: October 2026 Verified🔍 Last source review: 2026-10-18
GRI Editorial Comment
Evonik's REACH card shows the balance a specialty chemicals company has to strike: keeping compliance costs down in a high-mix, low-volume portfolio. "Evonik Tailor Made", extended in June 2026 through 2029, also concentrates resources on specialty areas where the return on REACH compliance is higher. GRI's suggestion for Japanese chemical and materials companies: in specialty fields where many Japanese companies compete, the quality of REACH registration, SVHC management and SCIP information is becoming a differentiator in supplier selection.
The SVHC Candidate List is usually updated twice a year; in 2026 it was updated once (February 4), and the next update is expected in June 2027. Progress on Evonik's restructuring may change. Please check the ECHA website and Evonik's investor relations pages for the latest information.
Mitsubishi Chemical Group
Mitsubishi Chemical Group Corporation
JapanAdvanced Materials
Adapting
⚡ Divesting non-core businesses and managing the transfer of REACH registrations
According to Mitsubishi Chemical Group (April 2025), it aims to divest or exit non-core businesses worth about ¥400 billion in revenue terms in FY2024–FY2029, of which about ¥280 billion had already been decided. The company targets core operating income of ¥236.0 billion in FY2029. For a non-EU manufacturer exporting chemicals to the EU, REACH Article 8 allows registration through an Only Representative (OR) in the EU; divestments make the transfer of REACH registrations a practical issue. On April 27, 2026, the European Commission said it would not open REACH for a full revision at this stage (the European Parliament Legislative Train lists the file as "Blocked", as updated on September 20, 2026).
🎯 Key Initiatives
Non-core divestments: according to the company, about ¥400 billion (revenue equivalent) targeted in FY2024–FY2029, with about ¥280 billion already decided (April 2025).
FY2029 target: the company targets core operating income of ¥236.0 billion.
Transfer of REACH registrations: divestments and transfers require changes to REACH registrants (for non-EU manufacturers, their Only Representative).
SVHC management: whether the substances added to the Candidate List in February 2026 (n-hexane, BPAF) are relevant to its processes and products needs to be checked.
⚠️ Challenges & Risks
•Transfers during divestments: changes of registrants, OR and SDS issuers are needed for substances linked to divested businesses; in joint venture restructuring, registrations may be split across several legal entities.
•Higher cost per product: after divesting commodity products, the remaining specialty portfolio has many low-volume grades, raising the relative cost of maintaining registrations and SVHC monitoring.
•Articles for new customers: suppliers of articles must provide SVHC information above 0.1% w/w (REACH Article 33) and information to ECHA's SCIP database under the Waste Framework Directive.
📢 Ongoing Compliance🕐 Verified: October 2026 Verified🔍 Last source review: 2026-10-18
GRI Editorial Comment
Mitsubishi Chemical Group's REACH card shows how restructuring and REACH compliance interact. Divesting non-core businesses is not only a cost measure; it also narrows the REACH portfolio to be managed. GRI's suggestion for Japanese chemical and materials companies: OR-based registration structures need to be managed actively as businesses are sold or transferred, not just maintained. The full REACH revision was shelved in April 2026.
Progress on divestments may change. Please check Mitsubishi Chemical Group's investor relations pages and the ECHA website for the latest information.
Sumitomo Chemical
Sumitomo Chemical Co., Ltd.
JapanDiversified Chemicals
Adapting
⚡ Restructuring petrochemicals and focusing on agro & life sciences and ICT & mobility while maintaining REACH compliance
According to its medium-term plan materials, Sumitomo Chemical recorded net income attributable to owners of the parent of ¥38.6 billion in FY2024 (year ended March 2025). According to its disclosures, under an agreement of August 7, 2024 it sold about 22.5% of Petro Rabigh to Saudi Aramco for $702 million; the sale was completed on October 8, 2025, reducing its stake from 37.5% to 15% (the proceeds were contributed in full to Petro Rabigh). Its FY2025–FY2027 medium-term plan ("Leap Beyond") focuses resources on Agro & Life Sciences and ICT & Mobility while continuing structural reform of petrochemicals in Japan and Singapore. Its REACH compliance spans different regulatory regimes for crop protection, semiconductor materials and polarizing film materials.
🎯 Key Initiatives
Petro Rabigh: according to the company, about 22.5% was sold to Saudi Aramco for $702 million under an agreement of August 7, 2024; the sale was completed on October 8, 2025, reducing the stake from 37.5% to 15%.
Medium-term plan (FY2025–FY2027): the company targets FY2027 sales revenue of ¥2.4 trillion, core operating income of ¥200 billion, ROE of 8%, ROIC of 6% and a D/E ratio in the 0.8 range.
Growth drivers: ROIC targets of 8% for Agro & Life Sciences and 11% for ICT & Mobility.
REACH and SCIP: REACH registrations and SVHC information for formulation additives, semiconductor materials and polarizing film materials, and SCIP information under the Waste Framework Directive, need to be managed together.
⚠️ Challenges & Risks
•REACH governance during petrochemical restructuring: registrations and SDS issuers need to be updated as businesses are reduced or transferred.
•Volume changes: when production volumes change, registered tonnage bands may need to be updated.
•New registrations: an expansion of semiconductor materials for the EU may require new REACH registrations and a cost-benefit assessment.
📢 Ongoing Compliance🕐 Verified: October 2026 Verified🔍 Last source review: 2026-10-18
GRI Editorial Comment
Sumitomo Chemical's REACH card shows REACH compliance continuing through a period of restructuring and recovery. Focusing on Agro & Life Sciences and ICT & Mobility is consistent with concentrating REACH compliance on higher value-added products. GRI's suggestion: for a diversified group spanning crop protection, pharmaceuticals, semiconductor materials and petrochemicals, managing the boundaries between several regulations and updating them as the portfolio changes is essential. Whether its REACH registration structure is updated accurately as petrochemicals are restructured matters to European business partners.
Petrochemical restructuring and crop protection regulation may change. Please check Sumitomo Chemical's investor relations pages and the ECHA website for the latest information.
Toray
Toray Industries, Inc.
JapanAdvanced Materials
Adapting
⚡ Developing a PFAS-free mold release film for semiconductors and managing chemicals across many businesses
Toray supplies fibers, carbon fiber composites, resins, films and other materials, and is affected by REACH across several businesses. According to its financial results, in the year ended March 2025 its revenue was ¥2,563.3 billion and core operating income was ¥142.8 billion (previous year: ¥102.6 billion); its outlook for the year ended March 2026 was ¥150 billion, including an estimated ¥15 billion negative impact from US tariff measures (May 2025). According to TORAY REPORT 2025, it has put into practical use a mold release film for advanced semiconductor packaging that uses its NANOALLOY® technology, reduces mold contamination to one fifth or less of conventional films, and is made of materials that do not contain PFAS, which are under consideration for regulation in Europe and elsewhere.
🎯 Key Initiatives
PFAS-free mold release film: according to TORAY REPORT 2025, a film using NANOALLOY® technology reduces mold contamination to one fifth or less of conventional films and is made of materials that do not contain PFAS.
Financial results: revenue of ¥2,563.3 billion and core operating income of ¥142.8 billion in the year ended March 2025 (company results materials).
Outlook: core operating income of ¥150 billion planned for the year ended March 2026, including the impact of US tariff measures (May 2025).
SVHC management: whether the February 2026 additions (n-hexane, BPAF) affect materials across its businesses needs to be assessed.
⚠️ Challenges & Risks
•Fluorine-free textiles: if the universal PFAS restriction is adopted (after the SEAC final opinion expected by end-2026, the Commission will propose a restriction for a vote in the REACH Committee), fluorinated water repellents for the EU would need replacing, while durability and repellency gaps remain.
•Carbon fiber composites: SVHC information has to pass through several tiers of prepreg makers, composite makers and Tier 1 suppliers.
•Multi-business impact: Candidate List additions need to be assessed across many businesses and prioritised.
📢 June 2025 Announcement🕐 Verified: October 2026 Verified🔍 Last source review: 2026-10-18
GRI Editorial Comment
Toray's REACH card shows an upstream materials maker dealing with REACH across several businesses. The PFAS-free mold release film described in TORAY REPORT 2025 is a concrete example of product development ahead of regulation. GRI's suggestion for Japanese materials makers: treating PFAS regulation as a driver of product innovation, not only a compliance cost, can become a source of competitive advantage, while businesses with different products and customers need dedicated compliance teams as well as a central system.
The SVHC Candidate List is usually updated twice a year; in 2026 it was updated once (February 4), and the next update is expected in June 2027. The PFAS restriction proposal and demand in the carbon fiber business may change. Please check the ECHA website and Toray's investor relations pages for the latest information.
Canon
Canon Inc.
JapanPrecision Instruments & Office Equipment
Adapting
⚡ Managing SVHC information as an article manufacturer through chemSHERPA
Canon makes multifunction devices, cameras, semiconductor lithography equipment and medical equipment, and has REACH obligations as a producer of articles rather than as a chemical maker: providing information on SVHCs above 0.1% w/w (Article 33), notifying ECHA where an SVHC is present above 0.1% w/w in articles totalling over one tonne per year (Article 7(2)), and providing information to the SCIP database under the Waste Framework Directive. According to the company, after adopting the IEC 62474 data scheme it began using chemSHERPA in 2017, and as of 2025 more than 99% of survey replies from suppliers were made through chemSHERPA.
🎯 Key Initiatives
chemSHERPA: according to the company, more than 99% of supplier survey replies were made through chemSHERPA as of 2025, which it says increased efficiency and reduced suppliers' administrative burden.
Support for suppliers: guide manuals in Japanese, English and Chinese for suppliers who have difficulty with the reply process (company website).
Data scheme: after adopting the IEC 62474 international standard data scheme, Canon began using chemSHERPA in 2017 (company website).
SCIP: providing information to ECHA's SCIP database for articles containing SVHCs above 0.1% w/w, required from January 5, 2021 under Article 9(1)(i) of Directive (EU) 2018/851.
⚠️ Challenges & Risks
•Candidate List updates: each addition requires a review of components, supplier surveys, customer information and SCIP updates. The SVHC Candidate List is usually updated twice a year; in 2026 it was updated once (February 4), and the next update is expected in June 2027.
•Remaining suppliers: suppliers outside chemSHERPA, including smaller and overseas suppliers, still need support.
•Core technologies: if components of toner, photoconductors or fixing materials were added to the Candidate List, redesign and customer qualification could take years.
📢 Ongoing Compliance🕐 Verified: October 2026 Verified🔍 Last source review: 2026-10-18
GRI Editorial Comment
Canon's REACH card shows chemical management by an article manufacturer. According to the company, more than 99% of supplier replies came through chemSHERPA as of 2025. The REACH duties of chemical makers and article makers are fundamentally different. GRI's suggestion for Japanese equipment and component makers: rolling out a shared data scheme such as chemSHERPA across the supply chain is a cost-efficient way to handle REACH, RoHS and future digital product passport requirements together. The shelving of the REACH revision in April 2026 does not reduce routine obligations such as Candidate List additions.
The SVHC Candidate List is usually updated twice a year; in 2026 it was updated once (February 4), and the next update is expected in June 2027. Annex XVII restrictions continue to change. Please check the ECHA website and Canon's official website for the latest information.
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